A consultant with 25+ years of transfer pricing experience, I represent clients in Canada and abroad with respect to various transfer pricing issues, compiling data and presenting supporting documentation for the intercompany transfer of tangibles, intangibles, and services.
My experience includes the preparation of transfer pricing reports, including industry, functional, and economic analyses, helping multinationals in establishing and defending their transfer pricing models and policies. Transfer pricing reports that I have prepared or managed have documented cost sharing arrangements related to the sharing of intellectual property development costs, the allocation of costs related to intra-group services, as well as the transfer of goods and intellectual property. I have experience preparing such documentation in conformity with the rules and regulations in Canada, the U.S., Europe, Asia and Australia. My experience also includes negotiations with tax authorities with respect to proposed transfer pricing adjustments to a company’s income or expenses.
I have assisted companies operating in various industries, including a significant number in the manufacturing, high-tech, software development, construction and engineering sectors, as well as distribution and service companies.